The Art. 50 obligation applies 2 August 2026 and was not deferred, whatever your risk tier. Touchpoint register, ready disclosure wording, and a machine-readable marking register.
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Art. 50 is the AI Act obligation most programmes discover last and owe first.
It applies whatever your risk tier. The chatbot you correctly classified as minimal risk is still caught. So is the marketing image your team generated last week. And unlike the Annex III high-risk regime, deferred to 2 December 2027, Art. 50 was not moved by the Digital Omnibus. It lands on 2 August 2026.
Programme plans are built around the biggest number on the page, which is the high-risk regime. Art. 50 is smaller, cheaper and sooner, and it sits with teams that are not in the compliance conversation: marketing generates content, support runs the chatbot, product ships the assistant. Nobody in that chain reads Annex III, and nobody told them they owe a disclosure.
The obligations — each paragraph of Art. 50, what it actually says, the touchpoint it typically bites on, and whether the provider or the deployer owes it. Including the artistic and satirical exception in 50(4), which limits how you disclose rather than removing the duty.
Touchpoint register — twelve pre-listed places an organisation touches a person with AI, from web chat to synthetic voice to AI-drafted email sent under a human name. Mark what is in use, which paragraph applies, and whether a disclosure exists. One formula tells you what is live and undisclosed, which is the number that matters.
Disclosure wording — sentences you can adapt, for each situation, with a note on the trap in each. A visible watermark, for instance, is not machine-readable marking; 50(2) asks for the output to be detectable as artificially generated.
Marking register — where synthetic content is produced, how it is marked, and whether that marking is machine-readable.
Compliance officers who need to know what is exposed before August, and the product or marketing owner who has to fix it. It assumes no legal background and produces an artefact you can hand to an auditor.
Is your organisation subject to both the AI Act and DORA? The two regulations intersect on the operational resilience of financial AI systems. Our sister site regulation-dora.eu covers DORA in depth — including what the AI Act adds on top of an existing DORA programme.
The AI Act for financial institutions ↗ Explore regulation-dora.eu ↗2 August 2026. It was NOT deferred by the Digital Omnibus, unlike the Annex III high-risk regime which moved to 2 December 2027. For most organisations it is the nearest real AI Act deadline.
Yes. Art. 50 is independent of the risk tier. A chatbot classified as minimal risk still owes the interaction disclosure, and a generative pipeline still owes machine-readable marking.
No. Art. 50(2) requires the output to be marked in a machine-readable format and detectable as artificially generated. A visible watermark may help a human but does not satisfy the machine-readable requirement on its own.